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2026 Proof of Custody. Published by Onramp Bitcoin. Editorial Independence.PrivacyTermsproofofcustody.io
Situation

I am rolling a 401(k) or IRA into bitcoin. Who actually holds it?

It depends on what sits under the wrapper. An IRA custodian must hold the asset, so a wallet you control alone is out by law; the choices are an ETF inside an ordinary brokerage IRA, a custodial bitcoin IRA at a single custodian, or an IRA built on multi-institution or collaborative custody. The columns to read are who holds the keys beneath the IRA, the custodian's fees against the balance, and whether the provider's inheritance process works for a beneficiary. Fees quoted as a percentage of assets compound with price; flat fees do not.

What decides it
  • Who holds the keys beneath the IRA wrapper
  • Fee basis against the balance
  • Beneficiary process
  • Roth versus traditional is a tax question, not a custody one

Which custody models fit, by the published rules

Fit engine rules 0.1 (1 Nov 2026), with this situation's inputs preset. Adjust the inputs to your own case.

Spot bitcoin ETF
fits · 80
  • The recoverer works with identity documents and institutions, not devices.
  • A spot ETF sits inside an ordinary brokerage IRA with no special custodian.

Recovery: The brokerage's beneficiary or estate process; no keys involved.

iShares Bitcoin Trust (IBIT)77Fidelity Wise Origin (FBTC)76Bitwise Bitcoin ETF (BITB)74ARK 21Shares (ARKB)70Franklin Bitcoin ETF (EZBC)70Grayscale Bitcoin Mini (BTC)69
Multi-institution custody
fits · 75
  • The recoverer works with identity documents and institutions, not devices.
  • Long horizons favour structures that do not depend on one party staying solvent and competent.

Recovery: Identity and authority documents to the institutions; no device, seed or ceremony on the heir's side.

Exchange or single-custodian account
fits · 70
  • The recoverer works with identity documents and institutions, not devices.

Recovery: Prove identity and, for an estate, present letters of administration to the company's support desk.

Swan IRA69Swan IRA68iTrust Capital65Bitcoin IRA60Alto IRA58BitIRA55
Qualified custodian
fits · 70
  • The recoverer works with identity documents and institutions, not devices.

Recovery: Identity and authority documents to the custodian; the custodian's own succession procedure.

Choice by Kingdom Trust73
Collaborative multisig
partial · 45

Fits only where the provider documents an assisted inheritance path the recoverer can follow with support; otherwise the arrangement becomes a puzzle box the day you are gone.

  • Long horizons favour structures that do not depend on one party staying solvent and competent.

Recovery: Locate the devices and seed backups, run a signing ceremony with the provider's key; or, where the provider documents an assisted inheritance path, follow that path with the provider.

Unchained IRA81Unchained IRA81

Excluded by the rules: Self-managed multi-vendor multisig (Recovery floor: this model requires the recoverer to run a hardware wallet and handle a seed phrase, and the person you named cannot be expected to.); Single-signature hardware wallet (Recovery floor: this model requires the recoverer to run a hardware wallet and handle a seed phrase, and the person you named cannot be expected to.)

These are custody models that fit the situation described, by Proof of Custody's published rules, version 0.1 (1 Nov 2026). They are not a recommendation to buy, sell, move or hold anything, and not legal, tax or estate advice.

Tests to run on any provider you shortlist

Trust or entity ownership

Bitcoin belongs to a trust, LLC or corporation, and the arrangement has to recognise the entity rather than an individual.

  • The account is titled to the entity, with entity documentation accepted at onboarding
  • Authorisation follows the entity's governance, including multiple trustees or officers where required
  • Trustee or officer changes can be processed without moving the bitcoin
  • Reporting suitable for the entity's accountant or auditor
Routing row IRA-02

Agent tool: fit_custody_setup. Primary sources: poc-scores. Refresh: scores monthly. All routes.

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